“liable to tax”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(29A)2,645 judgments

The decision most relied on for liable to tax is DIT v. NGC Network Asia LLC (313 ITR 187), cited in 144 judgments on BharatTax.

Leading authorities on liable to tax

DIT v. NGC Network Asia LLC

313 ITR 187 · 2009 · High Court

144

citing judgments

Where a duty is cast on the payer to deduct and pay tax at source under Section 195, the payee-assessee cannot be levied interest under Section 234B for failure to pay advance tax if the payer defaults on its TDS obligation. This principle may also extend to interest under Section 234C.

CIT v. Nestle India Ltd.

14 Taxmann 99 · 1983 · High Court

125

citing judgments

Club entrance fees, if incurred wholly and exclusively for business purposes, are allowable as revenue expenditure under Section 37(1). Furthermore, an order holding a deductor liable for TDS defaults under Section 201 must be preceded by an inquiry into the deductee's actual tax payment.

CIT v. Karnataka Power Corporation

247 ITR 268 · 2001 · Supreme Court

124

citing judgments

Income earned during the project construction stage, which has a direct nexus or is inextricably linked to the project's setting up, constitutes a capital receipt not liable to tax and reduces the project cost.

CIT v. Rasoi Ltd.

335 ITR 438 · 2011 · High Court

107

citing judgments

Sales tax subsidies and Industrial Promotion Assistance received under the West Bengal Incentive Scheme are capital receipts and therefore not liable to tax. The ruling clarifies the inapplicability of the Sahney Steel judgment to such subsidies.

(supra), Rama Bai v. CIT

181 ITR 408 · 1990 · Supreme Court

citing judgments

Interest received on delayed payment or enhanced compensation awarded under compulsory acquisition is a revenue receipt and is liable to income tax.

Bank Vs. ACIT (2005) 142 Taxman 98 (Kerala) (v) CIT(TDS) v. Director, DPS

115 ITD 411 · ITAT

citing judgments

The case is an authority regarding the conditions under which an assessee can be held liable, and orders confirmed, under Section 201(1) of the Income-tax Act for failure to deduct tax at source (TDS). It clarifies the circumstances for deeming an assessee to be in default for non-deduction or non-payment of TDS.

CIT v. Chaphalkar Brothers

351 ITR 309 · 2013 · High Court

citing judgments

A subsidy or incentive provided by the government for meeting capital expenditure, to achieve a national objective or public interest, is a capital receipt and thus not liable to income tax. The nature of the subsidy is determined by applying the 'purpose test'.

CIT v. Wipro Ltd. (

70 Taxmann.com 129 · Reported

citing judgments

Payments are liable for deduction of tax at source when they are in the nature of royalty. The withholding tax liability can be worked out by applying a proportion to the total remittance.

Judgments citing liable to tax

Amrinder Singh Khubber, Ambala vs. ITO, W-5, Ambala

ITA 1043/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh11 Nov 2025AY 2012-13

under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court in the case of T.N.K. Govindaraju Chetty

Linklaters LLP, London vs. Assistant Commissioner of Income Tax (International Taxation), Circle (3)(1)(2), Mumbai

ITA 1222/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Nov 2025AY 2022-23

Bench: Shri Saktijit Dey & Shri Girish Agrawalassessment Year: 2022-23 Linklaters Llp Assistant Commissioner Of C/O. Deloitte Haskins & Sells Income Tax (International Llp, Tower 3, 27-32 Floor, One Taxation) - 3(1)(2), International Centre, Mumbai Elphinstone Mill Compound, Vs. Senapati Bapat Marg, Elphinstone (West), Mumbai – 400 013. (Pan: Aabcl5182G) (Appellant) (Respondent) Present For: Assessee : Shri Niraj Sheth, Advocate Revenue : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 14.08.2025 Date Of Pronouncement : 11.11.2025

For Appellant: Shri Niraj Sheth, AdvocateFor Respondent: Shri Krishna Kumar, Sr. DR

Section 144C(5)Section 9Section 9(1)Section 9(1)(vii)

absence of permanent establishment in India as per Article 7(1) of the DTAA the income earned by the appellant is not liable to tax in India. 18. Without prejudice, the learned AD ought to have allowed deduction for entire expenditure instead of restricting to 5% of the total income ... Income-tax Act 24. Without prejudice to the above the learned AD erred in holding that entire receipt is liable to tax in India under Article 13 of the DTAA. The learned AO ought to have appreciated that as per Article 13(2) read with Article 13(7) only fees

Sri Koti Linga Hari Hara Mahakshetram Temple, Visakhapatnam vs. Income Tax Officer, Exemption WD, Rajahmundry

ITA 365/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam07 Nov 2025AY 2015-16

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.365/Viz/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Sri Koti Linga Hari Hara Vs. Income Tax Officer, Mahakshetram Temple, Exemption Ward, Visakhapatnam. Rajahmundry. Pan: Acgfs3064C (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri Cr Hemanth Kumar, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 03/11/2025 Hearing: घोषणा की तारीख/Date Of 07/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm :

For Appellant: Sri CR Hemanth Kumar, CAFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 10Section 12ASection 12A(2)Section 142(1)Section 147Section 148Section 167BSection 194ASection 250(6)Section 65

Andhra Pradesh Charitable and Hindu Religious Institutions and Endowments Act, and therefore, form part of the corpus and are not liable to tax under the Income-tax Act.” 2. Succinctly stated, the Assessing Officer based on the information available with the department noted that during the AY 2015-16 cash

JCIT(OSD), Circle -10(1), New Delhi vs. H B Leasing & Finance Company Limited, Delhi

In the result, Appeal of the Revenue is dismissed

ITA 1245/DEL/2025[1988-89]Status: DisposedITAT Delhi07 Nov 2025AY 1988-89

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Joint Commissioner Of Vs H B Leasing & Finance Income Tax, (Osd), Company Ltd. Circle 10(1), C. R. Building, H-72, Connaught Circus, I. P. Estate, Delhi Connaught Place, Delhi Pan:Aaach0713N Appellant Respondent C.O No. 94/Del/2025 ( In Ita No. 1245/Del/2025 A.Y. 1988-89) H B Leasing & Finance Vs Joint Commissioner Of Income Company Ltd. Tax, Osd, H-72, Connaught Circus, Circle 10(1) Connaught Place, Delhi C. R. Building, I. P. Estate, Pan:Aaach0713N Delhi

Section 132Section 158BSection 245

partake the character of income or income 19 ITA No. 1245/Del/2025 & C.O No. 94/Del/2025 JCIT (OSD) Vs. H. B. Leasing and Finance Company liable to tax. If an assessee receives admittedly a gift from a relation or earns agricultural income which is not subject to tax, then he would

Menaba Charitable Trust, Ahmedabad vs. The ITO, Ward-1(Exemptions), Ahmedabad

ITA 1361/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1361/Ahd/2025 िनधा"रण वष" /Assessment Year : 2017-18 Menaba Charitable Trust The Ito बनाम/ 26, Mahavir Jain Soc., Ward-1 (Exemptions) V/S. Bapunagar Ahmedabad – 380 015 Ahmedabad – 380 024 "थायी लेखा सं./Pan: Aaatm 2171 N (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Rushin Patel, Ar Revenue By : Shri C Dharani Nath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 17/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 24/12/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2017-2018. 2. The Assessee Raised The Following Grounds Of Appeal:

For Appellant: Shri Rushin Patel, ARFor Respondent: Shri C Dharani Nath, Sr.DR

Section 11Section 115BSection 250

corpus donations as anonymous as appellant failed to prove record of Menaba Charitable Trust vs. ITO Asst. Year : 2017-18 identity of donors liable to tax u/s115BBC(3), without any substantive basis or verification. The specific grounds are as under: 1.1 On the facts and in the circumstances

Mohit Vijaykumar Gupta, Mumbai vs. The DCIT, Circle-2(1)(1), Ahmedabad

In the result, the appeal of the assessee is partly allowed, Ground No

ITA 1091/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2021-22

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1091/Ahd/2025 िनधा"रण वष" /Assessment Year : 2021-22 Mohit Vijaykumar Gupta The Dcit बनाम/ B-1001, Juhu Trishul, Circle-2(1)(1) V/S. Gulmohar Cross Road No.6 Ahmedabad – 380 015 Jvpd Vile Parle West Mumbai – 400 049 "थायी लेखा सं./Pan: Adfpg 7162 D (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri J. C. Desai, Ca Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 06/08/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 14/12/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2021-2022. 2. The Assessee Has Raised The Following Grounds Of Appeal: Mohit Vijaykumar Gupta Vs. Dcit Asst. Year : 2021-22

For Appellant: Shri J. C. Desai, CAFor Respondent: Shri B.P. Srivastava, Sr.DR

Section 22Section 23(1)(c)Section 24Section 250

premises. In appeal, the assessee reiterated that the office premises were used for managing substantial investments in shares and securities, and hence not liable to tax under section 22. Alternatively, he pleaded that if the office premises were considered for taxation under the head “House Property”, the same should

Oxbow Energy Solutions B.V., Thane vs. The Deputy Commissioner of Income, Mumbai

The appeal of the assessee is partly allowed

ITA 4769/MUM/2023[2021-2022]Status: DisposedITAT Mumbai04 Nov 2025AY 2021-2022

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nishant Thakkar, Ms. JasminFor Respondent: Shri. Krishna Kumar, Sr. DR

Section 143(3)

grounds: “1. The Assessing Officer (AO) as well as the Dispute Resolution Panel (DRP) erred in assessing Rs. 37,63,060/- as income liable to tax in India. 2 Oxbow Energy solutions B.V. 2. The AO/DRP erred in holding that ASSESSEE has a business connection in India and that income

Mrs Shireen J. Dastur, Mumbai vs. ITO Int Taxation Ward 2(1)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 2204/MUM/2022[2018-19]Status: DisposedITAT Mumbai04 Nov 2025AY 2018-19

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2018-19 Shireen J. Dastur Income Tax Officer, 330, Coral Avenue, (International Taxation), New Port Beach, Ward 2(1)(1), California Vs. Mumbai 92662 Usa (Pan : Ctlpd0257N) (Appellant) (Respondent) Present For: Assessee : Shri P.J. Pardiwala, Sr. Advocate & Ms. Gunjan Kakkad, Advocate Revenue : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 11.08.2025 Date Of Pronouncement : 04.11.2025 O R D E R

For Appellant: Shri P.J. Pardiwala, Sr. Advocate and Ms. Gunjan Kakkad, AdvocateFor Respondent: Shri Krishna Kumar, Sr. DR

Section 144C(5)Section 234B

given by the ld. Assessing Officer in the draft order by submitting that the said receipt is an exempt receipt and therefore, not liable to tax even under the head “income from other sources”. According to her, onus is on the ld. 7 Shireen J Dastur AY 2018-19 Assessing ... existed a valid and justifiable consideration for making the said payment by the purchaser of the immovable property and therefore, it is not liable to tax u/s.56(2)(x). But ld. DRP did not deal with this aspect while giving its direction to the ld. Assessing Officer for passing

Cppgroup Services Limited, Leeds, United Kingdom vs. Assistant Commissioner of Income-Tax, Delhi

In the result, the appeal of the assessee is party allowed

ITA 980/DEL/2025[2022-23]Status: DisposedITAT Delhi04 Nov 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2022-23]

Section 143(3)Section 234B

India') as 'Fee for Technical Services' (FTS") under the Article 13 of the India- UK Double Tax Avoidance Agreement (DTAA') and hence liable to tax in India. 2. On facts and circumstances of the case and in law, the Ld. AO has erred in considering ... Company for rendering non-IT support services to CPP India as FTS under the Article 13 of the India-UK DTAA and hence liable to tax in India. 3. Without prejudice, the Ld. AO has grossly erred in applying an incorrect tax rate of 15% under Article

Kunal Rajendra Mashru, Mumbai vs. Asst Commissioner of Income Tax Circle -1, Junagadh

The appeal is dismissed

ITA 387/RJT/2025[2017-18]Status: DisposedITAT Rajkot03 Nov 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.387/Rjt/2025 निर्धारणवर्ष / Assessment Year: 2017-18 Kunal Rajendra Mashru C/O. Pradip Corporation, D-3, Jeevan Jyot, Cawasji Patel Street, Mumbai – 400001, Maharashtra Pan : Afhpm1835K (अपीलार्थी/Appellant) बनाम Vs. Assistant Commissioner Of Income-Tax Circle-1, Junagadh : (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Abhishek Choksy, Ar राजस्व की ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 05/08/2025 घोषणा की तारीख /Date Of Pronouncement : 03/11/2025 Order Per Dinesh Mohan Sinha: Captioned Appeal Filed By Assessee Pertaining To Assessment Year 2017-18, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By The Ld. Commissioner Of Income-Tax (Appeal), Addl/Jcit(A)-3, Chennai (In Short 'Cit(A)'), Dated 29.05.2025, Which In Turn Arises Out Of Assessment Order Passed By Assessing Officer U/S. 143(3) Of The Act On 07.11.2019.

For Appellant: Shri Abhishek Choksy, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr.DR

Section 10(2)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 56Section 56(2)(vii)

आयकर अपीलीय अधिकरण, राजकोट न्यायपीठ, राजकोट। IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI

Skechers Sarl, Mumbai vs. The Assistant Commissioner of Income Tax 4(2)(1), Mumbai

In the result the appeal filed by the assessee stands partly

ITA 2028/MUM/2025[2022-23]Status: DisposedITAT Mumbai03 Nov 2025AY 2022-23

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 143(3)Section 144CSection 144C(13)Section 153Section 234BSection 270A

DTAA, and in the absence of any Permanent Establishment in India, it would not be chargeable to tax in India, and hence, not liable to tax in India, Levy of interest under section 234B of the Act 6. erred in levying interest of INR 1,19,85,816 under section ... assessee thus submitted that, it also does not have PE/Business Connection in India, therefore the said commission income is not liable to taxed in India. The assessee, vide submission dated 23/10/2023, provided copy of TRC and No PE certificate before the Ld.AO. 3.3 Subsequently, on 26/02/2024, the Ld.AO issued another

Shri Chintamani Parshwanath Shwetambar Murtipujak Jain Sangh, Mumbai vs. Exem. Ward 2(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 5038/MUM/2025[2023-24]Status: DisposedITAT Mumbai31 Oct 2025AY 2023-24

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri J. Kala, CAFor Respondent: Shri Virbhadra Mahajan, Sr. DR

Section 11Section 11(2)Section 11(2)(a)Section 11(3)Section 115BSection 12ASection 143(1)

period of accumulation or during the year immediately following the expiry thereof, the amount which has not been so utilised will be liable to tax as income of the previous year immediately following the expiry of the accumulation period." In course of appellate proceedings the appellant has not furnished

B S R & Associates LLP, Mumbai vs. Principal Commissioner of Income Tax-8, Mumbai

In the result, appeal of the assessee is allowed

ITA 2397/MUM/2025[2018-19]Status: DisposedITAT Mumbai31 Oct 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri S. K. Aggarwal, Ajit Kumar Jain

Section 147Section 148Section 263Section 9(1)(vii)

services were in the nature of "fees for technical services" and the make available clause was also satisfied. Therefore, the said payments were liable to tax withholding which the Appellant had not done. c. The Appellant made detailed submissions vide letter dated 23 March 2022 [see Point 5...pages

M/S Enea Software Inc., India vs. Deputy Commissioner of Income-Tax, Circle Int. Tax 2(2)(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 986/DEL/2025[2022-23]Status: DisposedITAT Delhi31 Oct 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2022-23] M/S Enea Software Inc. Deputy Commissioner Of (Formerly Known As Openwave Income Tax, Circle Int. Tax Inc.), 1St Floor, Vs 2(2)(2), Civic Centre, Mobility Quattro Iconic Plot No. 273, Minto Road, Udyog Vihar, Phase 2, New Delhi. Gurugram, Haryana-122015 Pan- Aabco7261M Assessee Revenue

Section 142(1)Section 143(2)Section 144C

Tribunal in Appellant's own case for the Assessment Year 2019-20, that the consideration received by the Appellant is not liable to tax in India under the provisions of the DTAA, in light of the uncontroverted fact that there has been no change in any relevant facts and/or operations

Cpi India I Limited, Mumbai vs. Assistant Commissioner of Income-Tax, Circle Int Tax 1(2)(1), Delhi

In the result, appeal of the assessee is partly allowed

ITA 1826/DEL/2025[2018-2019]Status: DisposedITAT Delhi31 Oct 2025AY 2018-2019

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.1826/िद"ी/2025(िन.व. 2018-19) Cpi India I Ltd. C/O Vasa Chauhan & Associates, Off. No. 41, 3Rd Floor, Hi Life Premises, P M Road, Santacruz West, Mumbai, Maharashtra 400054 ...... अपीलाथ"/Appellant Pan: Aadcc-1505-G बनाम Vs. Assistant Commissioner Of Income-Tax, International Taxation 1(2)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By: Shri Dhanesh Bafna, (Through Vc) & Ms. Kashish Gupta, Chartered Accountants "ितवादी"ारा/Respondent By: Shri M.S Nethrapal, Cit-Dr सुनवाई क" ितिथ/ Date Of Hearing : 05/08/2025 घोषणा क" ितिथ/ Date Of Pronouncement : 31/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against Assessment Order Dated 31.01.2025 Passed U/S. 147 R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2018-19. 2. Shri Dhanesh Bafna, Appearing On Behalf Of The Assessee Submits That The Assessee Is A Tax Resident Of Mauritius. The Assesee Is An Investment Holding Company. The Assessee Has Obtained Global Business License From The Financial

For Appellant: Shri Dhanesh Bafna, (Through VC) &For Respondent: Shri M.S Nethrapal, CIT-DR

Section 112(1)(c)Section 147Section 48

Draft Assessment Order disagreed with the applicability of first proviso to section 48 of the Act and held that the assessee is liable to tax as per the provisions of section 112(1)(c)(ii) of the Act. The AO also denied Treaty benefit on Long Term Capital Loss determined

Snc Lavalin Inc., Delhi vs. The Assistant Commissioner of Income Tax/ Circle International Tax 3(1)(2), Delhi

In the result, the Appeal of the assessee is allowed, the Stay Application of the assessee is dismissed as infructuous

ITA 1760/DEL/2025[2022-23]Status: DisposedITAT Delhi30 Oct 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 143(3)Section 144C(1)

that "since no technical knowledge, skill etc. are made available by the assessee to its group companies, the same ought not to be liable to tax under the provisions of the India-Canada DTAA. 3 ITA No.- 1760/Del/2025 SNC Lavalin Inc. 3.2. However, the AO did not accept the above

Checkmate Facility & Electronic Solution Pvt. Ltd., Ahmedabad vs. The Dy. CIT, Circle-1(1)(1), Vadodara

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 234/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2017-18

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

For Appellant: Ms. Kinjal Shah, ARFor Respondent: Shri Rameshwar P Meena, Sr.DR

Section 244ASection 250

given to the Appellant and the addition be set aside to lower authorities for re-computing and allowing the correct figure of income liable to tax.” 17. The issue raised in above ground relates to addition made to the income of the assessee on account of difference in the income

Pvr Ltd., New Delhi vs. DCIT, Circle- 19(2), New Delhi

ITA 2080/DEL/2018[2013-14]Status: DisposedITAT Delhi29 Oct 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Krinwant Sahayassessment Year: 2011-12 Assessment Year : 2013-14 Dcit, Vs Pvr Ltd., Circle-19(2), 61, Basant Lok, New Delhi. Vasant Vihar, New Delhi. Pan: Aaacp4526D Assessment Year : 2013-14 Co No.47/Del/2022 (Ita No.1963/Del/2018 Assessment Year : 2013-14 Co No.41/Del/2016 (Ita No.5403/Del/2015) Assessment Year : 2011-12 Pvr Ltd., Vs Dcit, 61, Basant Lok, Circle-19(2), Vasant Vihar, New Delhi. New Delhi. Pan: Aaacp4526D (Appellants) (Respondents) Assessee By : Shri Sanjiv Kr. Choudhary, Shri Anil Kr. Chopra & Shri Praveen Kumar, Cas; & Shri V.K. Garg, Advocate, Revenue By : Ms Monika Singh, Cit-Dr

For Appellant: Shri Sanjiv Kr. ChoudharyFor Respondent: Ms Monika Singh, CIT-DR

No.41/Del/2016 8. Issue no. 6 arises out of Cross Objections filed by Assessee claiming that tax subsidy held as capital receipt not liable to tax under normal provisions of the Act also not taxable under the provisions of section 115JB. Since issue no.1 is decided against the revenue this issue

ACIT, Circle- 19(2), New Delhi vs. Pvr Ltd., New Delhi

ITA 1963/DEL/2018[2013-14]Status: DisposedITAT Delhi29 Oct 2025AY 2013-14

For Appellant: Shri Sanjiv Kr. ChoudharyFor Respondent: Ms Monika Singh, CIT-DR

DCIT, New Delhi vs. M/S. Pvr Ltd., New Delhi

ITA 5403/DEL/2015[2011-12]Status: DisposedITAT Delhi29 Oct 2025AY 2011-12

For Appellant: Shri Sanjiv Kr. ChoudharyFor Respondent: Ms Monika Singh, CIT-DR